2017 Physician Fee Schedule Final Rule

The Centers for Medicare & Medicaid Services (CMS)  has released the Medicare Physician Fee Schedule (MPFS) 2017 Final Rule, which sets the MPFS conversion factor at $35.8887 (up slightly from $35.8279 in 2016). The conversion factor accounts for a budget neutrality adjustment of 1.0050, a 0.5% update factor required by MACRA, and a slight downward change due to the non-budget neutral 5% Multiple Procedure Payment Reduction (MPPR) for the professional component of imaging services.

Significant changes under the final rule, to be enacted Jan. 1, 2017, include:

Quality Payment Programs

2017 will be the first performance year for Merit-Based Incentives Payment System (MIPS). The final rule changes were released on October 14, 2016 by the U.S. Department of Health and Human Services (HHS) in order to align the policies adopted for MIPS and Alternative Payment Models (APMs). The rules finalize a policy to streamline the quality validation audit process and, aside from any unusual circumstances, the results are used to modify an ACO’s overall quality score. The rules finalize revisions to references to the Quality Performance Standard and Minimum Attainment Level. The rules also revise policies regarding the application of flat percentages to provide that measures calculated as ratios are excluded from use of flat percentages when such benchmarks appear “clustered” or “topped out.” The rules modify Physician Quality Report System (PQRS) alignment rules to permit flexibility for EPs to report quality data to PQRS to avoid the PQRS and VM downward adjustments for 2017 and 2018 in cases where an ACO fails to report on their behalf. The rules also update the assignment methodology to include beneficiaries who identify ACO professionals as being responsible for coordinating their overall care.

Reduced Burden for Global Package Reporting

CMS finalized a data collection strategy for global services to reduce the reporting burden associated with the proposed rule following instructions from Congress to collect data to assess the resources used in furnishing pre- and post-operative care. Claims reporting of post-operative visits will be required only for high volume/high cost procedures instead of all global services. High volume/high cost procedures are those furnished by more than 100 practitioners, and are either furnished more than 10,000 times or have allowed charges of more than $10 million annually. Some additional rules are as follows:

1. The code ‘99024’ will be used to report post-operative visits instead of the proposed global surgery codes (G-codes).
2. Reporting will only be required for a sample of providers in practices of 10 or more in specified states.
3. Providers who are required to report would need to do so for services furnished on or after July 1, 2017.
4. Teaching physicians will be subject to the reporting requirements in the same way as other physicians and should use the GC or GE modifier as appropriate to indicate the involvement of residents.